Shipping Requirements 

When no other hazard classifications apply: Section 171.4 excepts marine pollutants in non-bulk packages from the requirements of the HMR when transported by motor vehicle, rail car, or aircraft. That means they are not subject to the requirements for shipping papers, markings, labels or placards when transported by highway, rail, or air. The markings and labels that were required to be affixed to the packages for transportation by vessel in accordance with the IMDG Code need not be removed or covered for subsequent transportation by other modes.

In addition, § 172.401(c) permits labeling in accordance with the IMDG Code, and §172.303(b)(3) permits the marking of a shipping name on a package when the name describes a material not regulated under the HMR. Although your material does not meet the definition of a hazardous material under the HMR, the package may remain appropriately marked and labeled in accordance with the IMDG Code and transit through the United States without shipping papers. However, if your shipment will not be accompanied by shipping paper, the marks and labels on your package may cause delays or otherwise frustrate its transportation. To avoid this problem, we suggest the following:

• Remove, obliterate, or securely cover the markings and labels;
• Leave the marking and labeling in place and describe the material as “Environmentally hazardous substances, liquid or solid, n.o.s.” in accordance with § 172.102, Special Provision 146; or
• Provide an indication on the package or bill of lading that the material is not regulated by the HMR. Alternatively, § 171.22(d) provides that material subject to the IMDG code, but not subject to the HMR, may be transported in the United States when described on a shipping paper, marked, and labeled in accordance with the IMDG code.